HomeMy WebLinkAbout01-02-08
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
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In Re: Estate of Ian Paul Dagan
ORPHANS' COURT DIVISION
NO. 21-07-0523
RE: Petition for Approval of Settlement of Wrongful Death Action
Pursuant to Orphans Court Rule 3 and Section 3323 of the Pennsylvania
Probate, Estates and Fiduciaries Code, as amended.
ORDER APPROVING DISTRIBUTION OF SETTLEMENT PROCEEDS
AND NOW, this ~ day of January, 2008, IT IS HEREBY ORDERED that
the settlement and proposed distribution of the settlement proceeds set forth in the
attached Petition is approved, and the proceeds from such settlement shall be paid as
follows:
1. The sum of $214,277.97 shall be paid to Paul P. Dagan and Vema J.
Dagan, as Administrators of the ESTATE OF IAN P. DAGAN, Deceased, in the survival
action claim brought as a result of the death ofIan Paul Dagan.
2. The sum of $321,416.96 shall be paid to Paul P. Dagan and Vema J.
Dagan, in their individual capacities in the wrongful death claim brought by them for
damages incurred by them, as individuals, as a result of the wrongful death of Ian Paul
Dagan.
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3.
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Nationwide Insurance Company shall retain $100,000.00 aridCErie -
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Insurance shall retain $387,232.97 of the settlement funds until the lien issue wifldhe r~
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Department of the Navy is settled, arbitrated or resolved by a separate court proceeding.
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4. The sum of $270,895.25 shall be paid to Salzmann Hughes, P.C. as
attorney fees.
5. The sum of $6,176.85 to Salzmann Hughes, P.C. as reimbursement for
expenses.
6. Should any of the remammg settlement funds in the amount of
$487,232.97 be paid to the Estate of Ian Paul Dagan and/or Paul P. Dagan and Vema J.
Dagan, these funds shall be allocated on the same percentage basis as used in Paragraphs
1 and 2. The attorney fees shall also be based on the same percentage as used in
Paragraph 3. Salzmann Hughes, P.C. shall also be entitled to reimbursement for any
additional expenses incurred in this matter. The Petitioners shall not be required to file a
new Petition for Approval of the Settlement Funds before dispersing the proceeds.
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
In Re: Estate of Ian Paul Dagan
ORPHANS' COURT DIVISION
NO. 21-07-0523
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PETITION FOR APPROVAL OF SETTLEMENT AND DIST~~O~
OF SETTLEMENT PROCEEDS PURSUANT TO 20 Pa.C.S.A. ~3323faJ~AND :J!.:
ORPHAN'S COURT RULE 3 )2 --'" 7:
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AND NOW, this
day of January 2008, comes Petitioners, Paul P.
Dagan and Vema J. Dagan, Administrators of the Estate of Ian Paul Dagan, by and
through their attorneys, Salzmann Hughes, P .C., and hereby respectfully petitions this
Honorable Court to approve the settlement and distribution set forth herein and, in
support thereof, avers as follows:
1. Petitioners are Paul P. Dagan and Vema J. Dagan, who were appointed
Administrators of the Estate of Ian Paul Dagan, deceased, by the Register of Wills of
Cumberland County, Pennsylvania on May 30, 2007. A copy of the Short Certificate
attached hereto and incorporated herein as Exhibit "A."
2. Petitioners are the parents of Ian Paul Dagan.
3. Ian Paul Dagan, then 16 years of age, died on February 14, 2007 as a
result of injuries and bums he sustained from a motor vehicle accident.
4. The above motor vehicle accident occurred on January 11, 2007, while the
decedent was a passenger in a vehicle being driven operated by Steven Snyder. The
police report of the accident is attached hereto and incorporated herein as Exhibit "8."
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5. At the time of his death, Ian Paul Dagan was not survived by a spouse or
children, and therefore the Petitioners are the sole beneficiaries entitled to bring an action
for wrongful death under the Wrongful Death Act, 42 Pa.C.S.A. ~8301(b).
6. Ian Paul Dagan died intestate, and under the laws of intestate succession,
the Petitioners are also the sole lawful heirs of the Estate of Ian Paul Dagan under 20
Pa.C.S.A. ~2103(2).
7. As a result of the accident in question and the death of Ian Paul Dagan,
Petitioners made a claim against the operator of the vehicle involved in the accident,
Steven Snyder, who at the time of the accident, was insured under a liability policy issued
by Nationwide Mutual Insurance Company (hereinafter "Nationwide").
8. Nationwide's insurance policy has liability limits of $100,000.00, which
Nationwide has tendered in full. See letter of October 8, 2007 from Nationwide attached
hereto and incorporated herein as Exhibit "C."
9. Petitioners also made a claim for underinsured motorist benefits under a
policy issued by Erie Insurance (hereinafter "Erie") with underinsured motorist limits of
$1,200,000.00, which Erie has tendered in full. See letter of September 19, 2007 from
Erie attached hereto and incorporated herein as Exhibit "D."
10. Both Erie and Nationwide have required Court approval for the
distribution of the settlement proceeds. No Court action or other proceeding has been
instituted, since these claims were amicably resolved without the necessity of such action.
11. Petitioners, as parents of Ian Paul Dagan, are entitled to recover wrongful
death damages individually due to the death of their son, which damages include the
pecuniary value of the services, society, and comfort that they would have received from
the decedent over their lifetime. Slaseman v. Myers, 309 Pa. Super. 537,455 A.2d 1213
(1983).
12. Petitioners are agreeable to allocating the sum of 40% to the survival
action to be paid to the Estate of Ian Paul Dagan. Petitioners further request that 60% be
paid to Paul P. Dagan and Verna Dagan, jointly, as proceeds of their claim for damages
under the Pennsylvania Wrongful Death statute.
13. The Pennsylvania Department of Revenue has agreed and approved an
allocation of 40% to the survival action and 60% to the wrongful death action. See letter
dated December 13,2007, attached hereto and incorporated herein as Exhibit "E."
14. Counsel respectfully requests approval of attorneys' fees in the amount of
33% of the recovery of Petitioners, excluding any amount paid as part of the below lien.
Said amount is consistent with Petitioners' counsel's fee agreement and represents a
reasonable fee for the services performed.
15. Counsel also respectfully requests approval of out-of-pocket expenses to
Salzmann Hughes, P.C. in the amount of$6,176.85.
16. The United States Department of the Navy has asserted a medical lien in
the amount of $387,232.97 against the settlement. Petitioners have disputed the validity
of this lien.
17. Erie has agreed to release the amount of $812,767.03 to the Petitioners
prior to the resolution of the lien issue with the Department of the Navy. See copy of
letter from Erie dated November 21, 2007 attached hereto and incorporated herein by
reference as Exhibit "F."
18. Until the issue of the Department of the Navy's lien is resolved at a later
date either through, settlement, arbitration or court proceedings, Erie has agreed to retain
the amount of $387,232.97 and Nationwide shall retain the amount of $100,000.00. See
Exhibit "F."
19. There are no other creditors of the Estate who have an interest in this
matter.
20. Petitioners have been fully informed and have consented to an
Authorization of Settlement including Distribution of Settlement Proceeds attached
hereto and incorporated herein as Exhibit "G."
WHEREFORE, Petitioners request that they be permitted to enter into the
settlement recited above, and that the Court enter an Order of Distribution as follows:
1. The sum of $214,277.97 shall be paid to Paul P. Dagan and Vema J.
Dagan, as Administrators of the ESTATE OF IAN Paul DAGAN, Deceased, in the
survival action claim brought as a result of the death of Ian Paul Dagan
2. The sum of $321,416.96 shall be paid to Paul P. Dagan and Vema J.
Dagan, in their individual capacities in the wrongful death claim brought by them for
damages incurred by them, as individuals, as a result of the wrongful death of Ian Paul
Dagan.
3. Nationwide Insurance Company shall retain $100,000.00 and Erie
Insurance shall retain $387,232.97 of the settlement funds until the lien issue with the
Department of the Navy is settled, arbitrated or resolved by a separate court proceeding.
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6. The sum of $270,895.25 shall be paid to Salzmann Hughes, P .C. as
attorney fees and the sum of $6,176.85 to Salzmann Hughes, P.C. as reimbursement for
expenses.
7. Should any of the remaining settlement funds in the amount of
$487,232.97 be paid to the Estate of Ian Paul Dagan and/or Paul P. Dagan and Vema J.
Dagan, these funds shall be allocated on the same percentage basis as set forth in the
Petition. Salzmann Hughes, P.C. shall also be entitled to reimbursement for any
additional expenses incurred and attorney fees at the same percentage as set forth in the
Petition.
SALZMANN HUGHES, P.C.
Date: I {'Z. ( 06
es . Hughes, Esquire
Atto ey LD. No. 58884
G ryan Salzmann, Esquire
ttorney LD. No. 61935
E. Ralph Godfrey, Esquire
Attorney LD. No. 77052
354 Alexander Spring Road, Suite 1
Carlisle, P A 17013
(717) 249-6333
Attorneys for Petitioners
VERIFICATION
The undersigned hereby certify that they are the Petitioners, and that the facts set
forth in the foregoing Petition are true and correct to the best of their knowledge,
information and belief; and further state that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. ~ 4904 relating to unsworn falsification to authorities.
t.~~antPr
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EXHIBIT A
STATE OF PENNSYLVANIA
( OUNTY OF CUMBERLAND
SHORT CERTIFICATE
I,
GLENDA FARNER STRASBAUGH
estate of IAN PAUL DAGAN
Register for the Probate of Wills and Granting
Letters of Administration in and for
CUMBERLAND County, do hereby certify that on
the 30th day of May, Two Thousand and Seven,
Letters of ADMINISTRATION
in common form were granted by the Register of
said County, on the
, late of MIDDLESEX TOWNSHIP
(Fitst, Middle, Last)
in said county, deceased, to PAUL P DAGAN
(Fitst, Middle, Lastl
and
VERNA J DA GAN
(First, Middle, Lastl
~nd that same has not since been revoked.
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the
seal of said office at CARLISLE, PENNSYLVANIA, this 30th day of May
Two Thousand and Seven.
File No.
PA File No.
Date of Death
S.S. #
2007-00523
21- 07- 0523
2/14/2007
591-96-3858
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NOT VALID WITHOUT ORIGINAL SIGNATURE AND IMPRESSED SEAL
EXHIBIT B
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COMMONWEALTH OF PENNSYlVANIA
!>>OLlCE CRASH RIEPORTING FORM
Case Closed Reportable Crash
. Y~5 0 No . Yes 0 No
Page
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1111111111111111111111111
Crash Number
I
AA500 1
W0049608
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Incident Number Police Agency Patrol Zone - -
~ 120070112M0255 II 21206 I 12 l
lij Agency Name Precinct Investigation Date (MM-DD-YYYY)
Q
e- I Middlesex Township I I MIDDLESEX I ~D~DI2007 I
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1>1 Dispatch Time (mil) Arrival Time (mil) Investigator Badge Number
<( 12045 II 2046 I ISGT. STEVEN KINGS BOROUGH I 13 I
]
'0 Reviewer Badge Number Approval Date (MM-DD-YYYY)
@. I K~R~N J ~IEHL 1i:;.1 I 2555 I ~{~~~~gI2007 I
-' "'-'-0" U, "._n... . . ..-..- -... -
County County Name Municipality Municipality Name Dav of Week
fiI EJ ICumberland I 1206 IIMiddlesex Township I o Sun . Thu
".
fiI o Mon 0 Fri
Q Crash Date (MM-DD-YYYV) Crash Time (mil) No of Units D Injured Killed" "If> 00
.G: ~D~DI2007 112044 103 D D complete o Tue o Sat
III
or Form F OWed 0 Unk
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y
Workzone (If Yes, ComP1ete 0 Yes . No 1 School Bus 0 Yes . No I School Zone 0 Yes . No Notify PENN DOT
Form M, Section 29) Related Related M...."~~
3~ Intersection Tl(Jle o 4W 'I '0 "Y.I '0 MJlti-le~ o Off Ramp o Railroad Crossing ~ @CJ
ay . ntersect,on ntersectlon Intersection I.2mkm 00
. Midblock o "T" Intersect'on 0 Traffic Circle! 0 On Ramp o Crossover o Other
I Round About " $<3<3 Ovewlil
- ....... --.. =--~
Route Number Segment (Optional) Travel lanes Speed Limit o North House Number (if applicable)
'l:I 11'575 I I I @O EJ c I I
III 0 o South
0 +'
Ill: Street Name Street Ending ~ o East For Mid-block crashes only, Use
4 iii I SHERWOOD I ~ II . West postal House Number and make sure
A. ..
U 0 o Unknown I Principal Roadway Street Name is
c: filled in if using this option
i:: B.wlte
I!. o Interstate o Turnpike o Turnpike o State o County . local Road o Private o Otherl
Signing (Not Turnpike) (EastIW~st) '_ Spur Hiqhway Road or Street Road Unknown
-- -...-.--
~ Route Number Segment (Optional) Travel Lanes Speed Umlt o North
'l:I ~ I I I I DD l:
Ii 3 o South ~
0 0
'J:;
Ill: " :l o East
r of Street Name Street Ending l:
5 ~ ~ I I D .!!! o West-
i (5 o Unknown
:! .s
i .. Bmtte o Interstate o Turnpike o Turnpike o State o County o local Road o Private Otherl
of Signing. 0
.. (Not Turnpike) (EastlWest) Spur Highway Road or Street ' Road Unknown
:S
--, .- .. .- --
- Intersecting Rt Num Or Mile Post Or Segment Marker I ;DN~ Feet
i! .. i! 1 II 1.01 10 I
~ .. to
-c 9: 0 South
" E Or Intersecting Street Name r Endin, ::l 0 East
.., l! Please -a
C v c 1 1 ~OWest Or Miles
:J 15 Enter j [LJ.O
.5! Information
6 ~ III for BOTH
l> Landmarks Intersecting Rt Num Or lVIile Post Or Segment Marker
... ~ if Using N I II 1.01 I ~DN"~ Distance From Crash
S .. This Option ~ Scene to landmark 1
c: 02 ..
Ii E 9: 0 South (For Crash between
i .. Or Intersecting Street Name St Ending ::l 0 East .J
:S -a Landmark 1 and
Q c I ID~owest
j Landmark 2)
7~ --- ,-
Degrees Minutes Seconds Degrees IVlinutes Seconds __J
latitude: ~ ~:~"~ longitude: - ~ ~:~"~
--.. <----
.~ Traffic Control Device o Yield Sign o Police Officer or TCD Functioning Emergency
_ Not Applicable o Traffic Signal o Active RR Crossing Ragman . No Controls 0 Device Functioning 0 Preemptive
o Other Type TCD Improperly
o Flashing Traffic Controls Signal
o Stop Sign o Passive RR o Unknown o Device Not 0 Device Functioning 0 Unknown
Signal Crossing Controls Functioning Properly
lAne Closed (If .Not App/icabJe":skip rest of the lAne Oowre section) I Lane Closure - -- -
l! 0 North 0 East o North and South 0 All
8 o Not Applicable 0 Partially . Fully 0 Unknown ~ o South 0 West _ East and West (N,S,E,W)
8 0 IDJffk:
" Yes. No 0 I ~O<30Min,
I: D1:1DJJml o 30-60 Min. . 1-3 hrs 0 3-6 hrs o 6-9 hrs o > 9 hours o Unknown
j Unknown 0
---_.~_.-.--- --=;':-:-';:,~,:-;-:..-;- - -- - - --- -'''' -- --
FORM. ""-500 (12102)
PENNDOT COPY
http://www.dot6.state.pa.us/iconslPrintImageslXmIFiles/20070022341KARENKIEHL200...1/17/2007
AA 500 2
I Police Use Only
Page:
1'[2]
IIIIIIII~ 1111111111111111
Crash Number I
.J
((t)WiIlMiliOllMmflE&ILVIXI (t)1F ~1E1i\'l1M$ivu..\fAND~
~D.lCE CMSIHI IRlE\PlO~YiING lFoutM
10
~ rYE!. . Motor Vehicle in 0 Hit & Run Vehicle 0 Illegally Parked o Legally Parked 0 Non - Motorized Commercial Vehicle
Transport
Unit o Pedestrian 0 Pedestrian on Skates, 0 Disabled from o Train o Phantom Vehicle o Yes . No
in Wheelchair, etc Previous Crash (If Yes, Complete Form C)
(If 'Pedestrian' or 'Pedestrian on Skates, in Wheelchair, etc', Comolete Form M, Section lB)
Unit No First Name IViI Date of Birth (MM-DD-VYYY),
~ I STEVEN I ~ EJ ~ 11990 I
Delete? Last Name Telephone Number
0 I SNYDER I I 7176972447 I
l': Address I City I State Zip
i 1138 LINDA DR MECHANICSBURG PA II 17050 I
Driver License Number State Class
0 128897596 I~ ~--.J
:5
r:
Oil Alcohol/DruQs Suspected Driver or Pedestrian Physical Condition
i:
.. o Illegal Drugs o Medication . Apparently o Illegal Drug
.. . No 0 fatigue 0 Medication
-S Normal Use
eI o Alcohol o Alcohol and Drugs o Unknown o Had B~gn o Sick
A. 0 Asleep 0 Unknown
- Drinkin
~ Alcohol Test Type Primary Vehlde Code Violation
~ o Test Not Given o Breath o Other Charged?
fI . Blood o Urine o Unknown if IDRIVING VEHICLE AT SAFE S I . Yes ONo
ii
:i Test Given
II Alcohol Test Results o Test Refused o Unknown Driver Presence 1 =Driver Operated 3=Driver Fled Scene
::- Results -L
[Q].~ o Test Given, QJ Vehicle 4=Hit and Run
Contaminated Results 2=No Driver 9=Unknown
Owner/Driver OO=Not Applicable 02=Private Vehicle Not 04=State Police Vehicle 07=Municipal Police Veh 09=Federal Gov Veh
~ 01 =Private Vehicle Owned! OwnedlLeased by Driver 05=PENNDOT Vehicle 08=Dther Municipal 98=Other
Leased by Driver 03=Rented Vehicle 06=Other State Gov Veh Government Vehicle 99=Unknown
Same as Ilowner First Name Owner Last Name or Business Name (If Pedestrian, skip this Section)
Driver 0 I RAY G I I SNYDER JR I
Address I City I State I Zip Vehicle Make .Make Code
I BOX 138 RD 4 LINDA DR MECHANICSBURG PA 170557 II Chevrolet I~
VIN Model Year Vehicle lViodel (see overlay)
IIGCEKI4H9BF304109 111981 I I 1
License Plate Reg. State Est. Speed Vehicle Towed Towed By
I YTL3115 I~ 1055 I . Yes ONo I MILLER AND SAM' 1
Insurance Insurance Company . Policy No
r: _Yes ONo o ~~~n I NA TIONWlDE INSURANCE I I 5837C788057 1
0
i l=Towing Pass. Veh 4=Mobile/Modular Home
.. Tra!linq ~ 7=Semi-Trailer Tag No Tag Year Tag St
2 0
11 Unrt No. of @] D 2=Towing Truck 5=Camper 8=Other I II I D
- Trailing Unrt
II Units: 3= Towing Utility Trailer 6=Full Trailer 9=Unknown
ii
:i Direction of EJ .Vehicle Position ~ .Movement ~ .See
eI Speciill UsaQe
> Travel Overlay
Vehicle Color Vehicle Type 05=Large Truck 20=Unicycle, Bicycle, ~ 12=Commercial
~ 06=Yellow ~ 01=Automobile 06=SUV Tricycle Passenger
07=Silver 02=Motorcycle 07=Van 21 =Other Pedalcycle OO=Not Applicable Carrier
08=Gold 03=Bus 10=Snowmobile 22=Horse & Buggy 01=Fire Veh 13=Taxi
02=Ambulance 21=Tractor Trailer
01=81ue 09=Brown 04=5mall Truck 11 =Farm Equip 23=Horse & Rider 03=Police 22=Twin Trailer
02=Red 10=Orange (If "OZ". Complete Form 12=Construction Equip 24= Train 08=Other Emergency 23= Triple Trailer
03=White 11 =Purple M, Section 26) 13=ATV 25= Trolley
04=Green 12=Other 18=Other Type Spec Veh 98=Other Vehicle 31=Modified Veh
(If "lO" or "21., Complete 11 =Pupil Transport g9=Unknown
05=Black 99=Unknown Form M, Section l7) 19=Unk. Type Spec Veh 99=Unknown
Initial Impact Point Damaqe Indicator Gradient 3=Downhill Road AIiQnment
~ OO=Non-Collision 14=Undercarriage ~ O=None 2zfunctional o 1 =Level 4=80ttom of Hill ~ 1=Straight
01-12=Clock Points 15=Towed Unit 1 =Minor 3=Disabling 2=Uphill 5=Top of Hill 2=Curved
13zTop 99=Unknown 9=lJnknown 9=Unknown 9=Unknown
- ....- ..--. --
W0049608
11
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FORM' M-500 (12002)
PENNDOT COPY
http://www.dot6.state. pa. us/icons/PrintImages/XmlFiles/20070022341 KARENKIEHL200... 1/17/2007
..J
COMMONWEALTH OF UJENNSVLVANIA
POLICE CRASH REPORTING FORM
Page
D
AA 500 3 I Police Use Only
A Person Type:
I=Driver
2=Passenger
7=Pedestrian
8=Other
9=Unknown
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B F =Female
M =Male
U =Unknown
IniuN Severity:
C O=Not Injured
I=Killed
2=Major Injury
3=Moderate
Injury
4=Minor Injury
8=lnjury, Unk
Severity
9=Unknown if
Injury
Seat Position:
D OO=Not A Passenger/Occupant
01 =Driver - All Vehicles
02=Front Seat Middle Position
03=Front Seat Right Side
04=Second Row. Left Side Or
Motorcycle Passenger
05=Second Row. Middle Position
06=Second Row - Right Side
07=Third Row Or Greater -
Left Side
08= Third Row Or Greater -
Middle Position
09= Third Row Or Greater -
Right Side
10=Sleeper Section of Truckcab
11 =In Other Enclosed
Passenger Or Cargo Area
12=ln Open Area
(Back Of Pickup, Etc.)
13= Trailing Unit
14=Riding On Vehicle Exterior
15=Bus Passenger
98=Other
99=Unknown
EMS Agency: ILlFE LION HELICOPTER
Safety fquioment One:
E OO=None Used / Not Applicable
01 =Shoulder Belt Used
02=Lap Belt Used
03=Lap And Shoulder Belt Used
04=Child Safety Seat Used
05=Motorcycle Helmet Used
06=Bicycle Helmet Used
10=Safety Belt Used Improperly
11 =Child Safety Seat Used Improperly
12=Helmet Used Improperly
90=Restraint Used, Type Unknown
99=Unknown
Safety fquioment Two:
F OO=None Used / Not Applicable
01 =Front Air Bag Oeployed (For This Seat)
02=Side Air Bag Deployed (For This Seat)
03=Other Type Air Bag Deployed
04=Multiple Air Bags Deployed
05=Motorcycle Eye Protection
06=Bicyclist Wearing Elbow/Knee/Pads
10=Air Bag Not Deployed, Switch On
11 =Air Bag Not Deployed, Switch Off
12=Air Bag Not Deployed,
Unk Switch Settinl1
13=Air Bag Removed (Prior To Crash)
19=Unknown If Air Bag Deployed
99=Unknown
~II~II~ I ~ 1111/11111/111
W0049608
~:
G O=Not Applicable
1 =Not Ejected
2= Totally Ejected
3=Partially Ejected
9=Unknown
Crash Number I
H Ejection Path.'
O=Not Ejected / Not Applicable
1= Through Side Door Opening
2=Through Side Window
3= Through Windshield
4= Through Back Door
5= Through Back Door Taill1ate Opening
6= Through Roof Opening (Sunroofl
C onvertible Top Down)
7= Through Roof Opening (Convertible
Top Up)
9=Unknown
~
~:
I O=Not Applicable
1 =Not Extricated
2=Extricated By Mechanical Means
3=Freed By Non - Mechanical Means
B=Other
9=Unknown
I Medical Facility: 1 PENN STATE HERSHEY MED ICAL CENTE
Unit No Person No Delete? Date of Birth (MM-DD-VYYY)
~~ 0 ~-~-11990
Name I Address / Phone
OSameas ISNYDER STEVEN R 138 LINDA DR MECHANICSBURG PA 17050717
Operator " ,
ABC DE F GH I
I[JEJEl~~~[]@]D
Unit No Person No I Date of Birth (MM-DD-YVYV)
EJ~ Dote? ~-~-11992
Name I Address I Phone
o soame as IERIKA FELTNER 6 GOLDENROD DRIVE CARLISLE PA 17015717395
perator I
I EMS Transport
. Yes 0 No
ABC DE F GH I
1[D[uEl~@Q~@]@]@]
Unit No Person No Date of Birth (MM-DD-VYYY)
~ ~ Delete? ~ r;-;---J I
~~ 0 ~-~-1990
Name / Address I Phone
o Same as IIAN P. DAGAN II BEAGLE CLUB ROAD CARLISLE PA 17013 71724
Operator I ,
I EMS Transport
.Ves DNa
ABC DE F GH I
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-
Unit No Person No "1 Date of Birth (MM-DD-YYYY)
00 D~~~r 0-0-1
Name / Address I Phone
o Same as I
Operator
I EMS Transport
. Ves 0 No
ABC D E F G-H ~
IDDDOOODDD
Unit No Person No Date of Birth (MM-DD-VYYY)
o 0 D~te? 0-0-1
Name / Address / Phone
o Same as I
Operator
Unit No Person No
DO
I EMS Transport
DVes DNo
ABC 0 E F '-G--- H I
IDDDOOODDD
I ? Date of Birth (MM-DD-YYYY)
Dote 0-0-1
Name / Address / Phone
o Same as I
Operator
FORM' AA-SOO (12102)
I EMS Transport
DVes DNo
ABC DE F GH I
IDDDOOODDD
I EMS Transport
DVes DNa
PENNDOT COpy
http://www.dot6.state. pa. us/iconslPrintImages/XmlFiles/20070022341 KARENKIEHL200... 1/17/2007
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COi\lliliiON\J\tIEAlTH OF PIENNSVl\lANIA
POLICE CRASH REPORTING FORiIii
AA 500 4 I Polic. Use Only
r?l ll=Non-Comsion
L:...J 1 =Rear End
c ..
~~ - -
~ ! Relation to Roadway f2I 1=On Travel Lanes 3=Madian
.2 ~ U 2=Shoulder 4=Roadside
15 .E :~~' . . [] 1=Daylight
-t;; -~ /" ummat/on 2 2=Dark . No
5 ;: _ Streel Ughts
.. · r1l 1 =No Adverse
Ii r...." CMdi"~ u 2'~'~~_ =:.'....
\:I :s I Road Surface Conditions fOl O=Dry 2=~f1nd, Mud, Dirt,
U 1 =Wet 3=Snow Covered
= = . Harm Eveiii "UR Most? UtilltYPole Number - -.
1 f23I fLl . 147277
Unit No ~ L:J .
EJ20001
0001
40001
Crash DescriPtion
2=Head On
3=Rear to Rear
(Backlng)
- 3=Dark . Streei
Lights
4=Dusk
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16 ~
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.E
Please Put 3
Events in
Sequential
Order
Please P!lt 3 r-1 D
Events m L--.J
Sequential
Order 4 0 0
First
T1i1mfu/
Event m
the Crash
Unit No Harm Event
~[~]
Unit No Harm Event
~~
Most
1li1mful
Event m
the Crash
Do nol repeal this inlormalion on multiple ~
c
o
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to
E
~
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c:
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.a
'1:
1:
o
u
Environmental I Roadway
Potential Fadors (EIR) 1
OO=None
01 =Windy Conditions
02=Sudden Weather Conditions
03=Other Weather Conditions
04=Deer In Roadway
OS=Obstacle On Roadway
06=Other Animal In Roadway
07=Glare
08=Work Zone Related
~ 20 30
11 =Slippery Road Conditions (kelSnow)
12=Substance On Roadway
13=Potholes
14=8roken Or Cracked Pavement
15= TeD Obstructed
16=50ft Shoulder Or Shoulder Drop Off
28=Other Roadway Factor
29=Other Environmental Factor
99=Unknown
Possible Vehicle Failures (V)
DO=None 06=Exhaust
01=Tires 07=Headlights
02=8rake Syslem 08=Signal Lights
03=Steering System 09=Other Lights
04=Suspension Ill=Hom
OS=Power Train 11 =Mirrors
~~itEJ1~20
~~~D1020
12=Wipers
13=Driver Seating/Control
14=Body, Doors, Hood, Etc
15= Trailer Hitch
16=Wheels
17=Airbags
18= Trailer Overloaded
19=Unsecure/Shifted
Trailer Load
20=lmproper Towing
21=Obstructed Windshield
99=Unknown
(
Indicated Prime Fador
00 not rep"1 1his informalion on
mul,iple__
fiR V 0 P
00.0
If fIR is the Prime Fador
Type, leave Unit No blank
Un~ No Factor Code
~~
FORM' AA.500 (12102)
PENNDOT COpy
Page
~
III "'I'~ /111111111111111
Crash Number
I
W0049608
4=Angle
5=Sldeswlt!e
(Same Direction)
6=Sldeswipe
(Opposite Direction)
7=Hit Fixed Object
l\;HIl Pedestrian
9=Other/Unknown J
5=Outside Trafficway 7=Gore (Ramp Intersection) J
_ 6=ln Parking Lane __ 9=Unknown
~:~i~;w~~~~~~ ... B~6::~,.~.~--"-n '__'~:__u_ __ ___ ._~ 1
5=Fog 7=Sleet & Fog 9=Unknown J
6=Rain & Fog 8=Other
4=Slush 6=lce Patches" -u 8:~t~~r - -'--=""]
5=lce._ _ 7=~~Jv;n~tanding, _____ --'7-'--'-=_~
Harmful Events (Harm Event) 30=Hit Fence Or Wall
OI=Hit Unit 1 31=Hit Building
02=Hit Unit 2 32=Hit Culvert
03=Hit Unil 3 33=Hit Bridge Pier Or Abutment
04=Hit Unit 4 34=Hit Parapet End
05=Hit Unit 5 35=Hit Bridge Rail
06=Hit Other Traffic Unit 36=Hit Boulder Or Obstacle
07=Hit Deer On Roadway
08=Hit Other Animal 37=Hit Impact Attenuator
09=Collision With Other Non 38=Hit Fire Hydrant
Fixed Object 39=Hit Roadway Equipment
11 =Struck By Unit 1 4ll=Hit Mail Box
12=Struck By Unit 2 41=Hit Traffic Island
13=Struck By Unit 3 42=Hit Snow Bank
14=Struck By Unit 4 43=Hit Temporary Construction
15=Struck By Unit 5 Barrier
16=Struck By Other Traffic Unit 48=Hit Other Fixed Object
21=Hit Tree Or Shrubbery 49=Hit Unknown Fixed Object
22=Hit Embankment 50=OverturnIRolI Over
23=Hit Utility Pole 51 =Struck By Thrown Or Falling
24=Hit Traffic Sign Object
25=Hit Guard Rail 52=Pot Holes Or Other
26=Hit Guard Rail End Pavement Irregularities
27=Hit Curb 53=Jacknife
28=Hit Concrete Or 54=Fire In Vehicle
Longitudinal Barrier 58=01her Non-Collision
29=Hit Ditch 99=Unknown Harmful Event
Driver ActiOn (0'--- .-.-. --
OO=No Contributing Action
01 =Driver Was Distracted
02=Driving Using Hand Held Phone
03=Driving Using Hands Free Phone
04=Making Illegal U-Turn
05=lmproperlCareless Turning
06= Turning From Wrong lane
07 =Proceeaing WIO
Clearance After Stop
08=Running Stop Sign
09=Running Red Light
10=Failure To Respond To
Other Traffic Control Device
11=Tailgating
12=Sucfden SlowilllliStopping
13=lIIegally Stoppea On Road
14=Careless Passing Or lane
Change
15=Passing In No PaSSing Zone
16=Driving The Wrong Way On
I-Way Street
~~It~ 1~203040
0203040
17 =Careless Or Illegal
8acking On Roadway
18=Driving On The Wrong
Side Of Road
19=Making Improper
Entrance To Highway
20=Making Improper EXll
From Highway
21=Careless ParkinglUnparking -1
22=Over/Under
Compensation At Curve
23=Speeding
24=Driving Too Fast For Conditions
25=Fallure To Maintain Proper Speed
26=Driver Fleeing Police (Pol Chase)
27 =Driver Inexperienced
28=Failure To Use Specialized Equip
92=Affected 8y Physical Condition
98=Dther Improper Driving Actions
99=Unknown
Unit 0 1
No
Pedestrian Action (P')
OO=None
01=Entering Or Crossing At
Specified Location
02sWalkirn;l. Running, Jogging,
Or PlaYln9
Unit NO~
03=Working
04=Pushing Vehicle
05=Approaching Or Leavin9 Vehicle
06=Worlcing On Vehicle
07=Standing
98=Other
99=Unknown
@C] Unit NoD 0
http://www.dot6.state.pa.uslicons/PrintImages/XmIFiles/20070022341 KARENKIEHL200...
1/17/2007
--1
COMMONWEALTH OF PENNSYLVANIA
POLICE CRASH REPORTING FORM
AA 500 5 I Police Use Only
Page
~
~I mllllllllllllmllU Crash Number I
(
W0049608
20
I)
E
I!
III
"
Q
Witness Name Address Phone
1 1
2
Narrative and additional witnesses: Accident Investigation Notification Issued7 . Property Damage.
This accident occured when unit #1 was traveling west on Sherwood Drive
and entered a dip in the roadway with a right uphill bend on the exit. The
driver of unit #1 failed to negotiate the right bend in the roadway and slid
across the oncoming lane of traffic a measured 75 feet before imp acting with
PP&L utility pole #47277/S34321 with the left front portion of the unit. Upon
impact, the utility pole snapped off at ground level and the unit was forced
into a counter-clockwise slide. The unit slid a measured 59 feet sideways
II before starting to roll over onto the pasengers side where it slid another 22
>
-;; feet before rolling over completely one time and continuing to roll until
l!
.. coming to rest back on it's roof 122 feet from the initial impact point,in a
/I
z field to the northwest of southwest of the impact point. Upon coming to rest,
"0
c all occupants extricated themselves from the unit.
" The driver of unit #1 was intervie wed on 1-16-07 and reported that he was
WI
2 ; traveling west on Sherwood Drive and was unfamiliar with the roadway. As he
S
i entered the bend/dip in the roadway and started uphill, his unit struck a
"bump" on the roadway which "jolted" the st eering wheel. He could not see the
road and then observed the utility pole in front of him. He applied the brakes
and struck the pole with the drivers front portion of the unit. The unit then
rolled before coming to rest on it's roof and everyone climbing out on their
own power. He reported that passenger DAGAN Was complaining to pain in one of
his legs after exiting the overturned unit. The driver went on to report that
he could not see his speedometer real well because the dash lights were out,
but that the last he did look down, which was just prior to impact, the
speedometer was showing in the area of 45 mph.
Passenger FELTNER was interviewed on 1-16-07 and reported that they were
fORM. ""-500 (12J02)
PENN DOT COpy
c
http://www.dot6.state.pa.us/icons/PrintImages/XmIFiles/20070022341KARENKIEHL200...1/17/2007
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W0049608
Crash Number J
http://www.dot6.state. pa. us/icons/PrintImages/XmlFiles/20070022341 KARENKIEHL200... 1/17/2007
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Changel
Continuation
M 500 N I Police Use Only
Narrative and additional witnesses:
22 travling west on Sherwood Drive around a curve when she didn't see the road in
front of them anymore, but saw the pole. She closed her eyes and put her head
between her legs and felt the impact and then fell forward. The unit rolled and
when it stopped she noticed she was hanging upside down in the lapbelt and
attempted to get out, but could not until she got her right leg free from under
the dashboard. She then crawled out the broken drivers side window. No
state ment was available from passenger DAGAN because of injuries he sustained
after the accident was over.
lD
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FORM' AIWOON (.-,
PENNDOT COpy
(
Crash Number: W0049608
Incident Number: 20070112M0255
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http://www.dot6.state. pa. us/iconsIPrintlmages/XmlFiles/20070022341 KARENKIEHL200... 1/17/2007
EXHIBIT C
D
Nationwide@
On Your Side'"
One Adams Place · 300 Seven Fields Blvd. suite 300 · Seven Fields, PA 16046
October 8,2007
Salzmann Hughes PC. Ralph Godfrey, Attorney
354 Alexander Spring Rd
Suite 1
Carlisle, PA 17015
OUR INSURED: Ray G & Kathi J Snyder
OUR CLAIM NUMBER : 5837 C 7880570111200701
YOUR CLIENT: Ian Dagan
DATE OF LOSS: 01-11-2007
Dear Mr. Godfrey:
We are prepared to offer the policy limits of $100,000 to settle this claim. However, we have been put
on notice of a lien by the Dept. of the Navy. We are prepared to put their name on the check until you
have the lien matter worked out. We would require Court approval and that a release be signed by the
Estate. Please advise if you are in a position to accept the settlement, at this time.
Nationwide Mutual Insurance Company
Rita Kania, SCLA (PA-20-SVEN)
Claims Department
(724 )933-5669
cc:
Department of the Navy Attn Eve Doptis, nc0704042
Any person who knowingly and with intent to defraud any insurance company or other person frles an
application for insurance or statement of claim containing any materially false information or conceals for
the purpose of misleading, information concerning any fact material thereto commits a fraudulent
insurance act, which is a crime and subjects such a person to criminal and civil penalties.
EXHIBIT D
I ~~~anCEf
Branch Office' 4901 Louise Drive. Rossmoyne Business Center · Mechanicsburg, PA 17055. (717) 795-8200. Toll Free 1-800-382-1304
Adjuster Mailing Address. P.O. Box 2013 · Mechanicsburg, P A 17055 . Adjuster Direct Line: (717) 697-7661 . Fax: (717) 691-4760.
Date: September 19,2007
E. Ralph Godfrey, Esquire
Law Offices
354 Alexander Spring Road
Suite 1
Carlisle, P A 17015
RE: Erie Claim #: 010170901365
Erie Insured: Paul & Vema Dagan
Date of Loss: 01111/2007
Your Client: Estate of Ian Dagan
Dear Mr. Godfrey:
I am sending this in regard to the Underinsured Motorist claim on behalf of the Estate of Ian Dagan. Thank
you for the information you supplied with your letter dated September 10, 2007. Upon review of the
available information, please be advised that Erie is now in a position to offer our insured's $1,200,000.00
policy limit as settlement of this Underinsured Motorist claim. I have enclosed our proposed release. Since
this is a fatal we will also require the settlement to be court approval.
We . will still need to resolve the issue of the Department of the Navy lien before Erie can proceed with the
issuance of any settlement check(s).
Upon receipt of the court approval, the executed release and the resolution of the Department of the Navy
lien, I will issue the settlement check(s). Please provide your tax id number as well.
Thank you for your cooperation in this matter.
The ERIE is Above Allin Service<&>. We commit, care and serve. It's our true blue promise.
EXHIBIT E
WEB ADDRESS www.state.pa.us
BUREAU OF INDIVIDUAL TAXES
INHERITANCE TAX DIVISION
Po Box 280601
HARRISBURG, PA 17128-0601
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF REVENUE
December 13, 2007
E. Ralph Godfrey
Salzmann Hughes, PC
354 Alexander Spring Rd., Ste. 1
Carlisle, PA 17015
Re: Estate of Ian P. Dagan
File Number: 2107-0523
Date of Death: 2/14/07
Court Number: CCP Cumberland Co. No. 21-07-0523
Dear Mr. Godfrey:
The Department of Revenue received a petition concerning the approval of Settlement
Claim to be filed on behalf of the above-referenced Estate in regard to a wrongful death and
survival action. It was forwarded to this Bureau for the Commonwealth's approval of the
allocation of the proceeds paid to settle the actions.
Pursuant to the petition, the 16-year~0Id-decedent died as a result of a motor vehicle
accident. The heirs to the decedent's estate are his parents. Therefore, any proceeds paid to
settle the survival action would pass to the decedent's parents and would be subject to a zero
percent inheritance tax rate. 72 P.S. 99116(a)(1.2). Accordingly, regardless of the allocation
of the subject proceeds, there would be no inheritance tax consequences.
Please be advised that based upon these facts and for inheritance tax purposes only,
this Department has no objection to the proposed allocation of the gross proceeds of this
action, 60% to the wrongful death claim and 40% to the survival claim. Proceeds of a survival
action are an asset included in the decedent's estate and, although subject to the imposition of
a zero percent inheritance tax rate in this instance, they must be reported on decedent's
Pennsylvania inheritance tax return. 42 Pa. C.S.A. 98302; 72 P.S. 999106,9107. Costs and
fees must be deducted in the same percentages as the proceeds are allocated. In re Estate of
Merrvman, 669 A.2d 1059 (Pa. Cmwlth. 1995).
I trust that this lett~r is a sufficient representation of the Department's position on this
matter. As the Department has no objections to the Petition, an attorney from the Department
of Revenue will not be attending the hearing regarding it. Please contact me if you or the Court
has any questions or requires anything additional from this 'Bureau. Finally, the approval of this
allo~tion is limited tothi$estate and does not reflect the position that the Department may
take in any other proposeQ.pistribution of proceeds ofa wrongful death/survival action.
. . ~ 1 .,
SEJ:tMCC~~~ t-
Holly A. McClintock
Trust Valuation Specialist
PHONE: 717-787-1794 - FAX: 717-783-3467- EMAll: hmcclintoc@state.oa.us
EXIBIT F
'.
I,ll Erie
. ~Insurance"
Branch Office' 4901 Louise Drive. Rossmoyne Business Center. Mechanicsburg, P A 17055 · (717) 795-8200. Toll Free 1-800-382-1304
Adjuster Mailing Address. P.O. Box 2013 . Mechanicsburg, PA 17055 . Adjuster Direct Line: (717) 697-7661 · Fax: (717) 691-4760
Date: November 21, 2007
E. Ralph Godfrey, Esquire
Law Offices
354 Alexander Spring Road
Suite I
Carlisle, P A 17015
RE: Erie Claim #: 010170901365.
Erie Insured: Paul & VernaDagan
Date of Loss: 01/11/2007
Your Client: Estate of Ian Dagan
Dear Mr. Godfrey:
This letter is being sent in response to your faxed letter dated November 14,2007. After review of the
information that Erie has available at this time, please be advised that Erie is prepared to issue a check in the
amount of$812,767.03 and hold the remaining balance of $387,232.97 in preparation for settlement of the
lien asserted by the Department of the Navy. Erie has been specifically requested by the Department of the
Navy to submit a check for their final claim amount of $387,232.97 via letter dated November 7, 2007. I
have enclosed a copy of that letter for your review. Since it appears you are contesting the lien being
asserted by the Department of the Navy, Erie will hold the money for the lien until Erie has received written
correspondence from you, as well as the Department of the Navy, indicating that any issue regarding the lien
has been resolved. Any distribution of funds will be contingent upon receipt of court approval.
Please forward a letter, or copies of any correspondence you have had with the Department of the Navy, that
will outline your dispute of their asserted lien.
Thank you for your cooperation.
cc: P .A. Myers, Managing attorney for Medical Care Recovery Units
The ERIE Is Above Allin Service"'. We commit, care and serve. It's our true blue promise.
EXHIBIT G
..
AUTHORIZATION FOR SETTLEMENT
We, Paul P. Dagan and Vema J. Dagan, husband and wife, individually and as
Administrators of the Estate of Ian Paul Dagan, have agreed to the settlement consisting of
$100,000.00 from Nationwide Mutual Insurance Company and $1,200,000.00 from Erie Insurance
Group as a result of the accident involving our son, Ian Paul Dagan on January 11, 2007. We
understand that the United States Department of the Navy has asserted a lien against the settlement
and that we may be responsible for paying this medical lien in the amount of $387,232.97. We are
also responsible to pay applicable costs and expenses of the investigation as well as the applicable
contingency fee to our attorneys, Salzmann Hughes, P.C., pursuant to our Fee Agreements. We
have reviewed the Statement of Distribution attached hereto and incorporated herein by this
reference, and have agreed to the allocation and payments as set forth therein. We understand that
the United States Department of the Navy may compromise its claim, and in the event this occurs,
the remaining amount of the settlement proceeds shall be distributed in like accordance with the
Settlement Agreement.
We understand that this will end our case against the driver of the vehicle and the
underinsured motorist action and that we will be required to sign a release, which will forever
preclude us from making any claims because of this accident. We expressly acknowledge that
our recovery will be limited to the above amount. We also have discussed or have had an
opportunity to discuss this settlement with our counsel, and we are voluntarily and knowingly
entering into this settlement. No promise or inducement has been made to us and in settling this
case.
'\
We direct Salzmann Hughes, P.C., to file the appropriate paperwork with the Court to
conclude this matter. We also agree that we have reviewed the Petition for Approval of Settlement
and Proposed Order in detail and agree to its contents.
Dated: /;'/1/07
Paul P. Dagan, A .. strator on behalf of the Estate
of Ian Paul Dagan
Dated: L ~/3J/()1
Dated: I 0/ 3(~ 7
Dated: I iJ-j31/ l>1
~ .
STATEMENT OF DISTRIBUTION
Gross Recovery
Withheld amount
Less Distribution
Attorney Fees to Salzmann Hughes, P.C.
Expenses to Salzmann Hughes, P.C.
Payment of Liens
Wrongful death allocation
60%
Survival Action
40%
SUMMARY
Total to Client
Total to Salzmann Hughes, P.C.
Total for Liens
Total held in escrow
Total Summary
~~I fOr-
$1,300,000.00
$487,232.97
$270,895.25
$6,176.85
$0.00
$321,416.96
$214,277 .97
$535,694.93
$277,072.10
$0.00
$487,232.97
$1,300,000.00
..
12/4/2007
1:07 PM
Salzmann Hughes, P.C.
Slip Listing
Page
1
Selection Criteria
Slip.Transaction Dat
Clie.Selection
Clie. Selection
Slip.Transaction Typ
Slip. Classification
Clie.Selection
Slip.Transaction Typ
Earliest - 11/30/2007
Include: Dagan, Paul, P.
Include: Dagan, Paul, P.
2-2
Open
Include: Dagan, Paul, P.
2-2
Rate Info - identifies rate source and level
Slip ID
Dates and Time
Posting Status
Description
20224 EXP
2/6/2007
WIP
Middlesex Police Department- copy of police report
24260 EXP
5/14/2007
WIP
Verzilli & Verzilli Consultants
26311 EXP
5/30/2007
WIP
Register of Wills
26317 EXP
6/11/2007
WIP
MRO Corporation
26598 EXP
6/27/2007
WIP
1.0.D. Incorporated- Copies of medical records
27721 EXP
7/23/2007
WIP
iod incorporatedllan Dagan-Hershey Medical Center
29496 EXP
8n /2007
WIP
Robson Forensic-expert
Timekeeper
Activity
Client
KEW
Cost Advance
Dagan, Paul, P.
DHM
Cost Advance
Dagan, Paul, P.
KLC
Cost Advance
Dagan, Paul, P.
KLC
Cost Advance
Dagan, Paul, P.
ERG
Cost Advance
Dagan, Paul, P.
ERG
Cost Advance
Dagan, Paul, P.
DHM
Cost Advance
Dagan, Paul, P.
Units
DNB Time
Variance
1
Rate
Rate Info
Bill Status
15.00
1
1500.00
47.00
996.83
1
75.85
75.85
1000.00
Slip Value
15.00
1500.00
47.00
996.83
75.85
75.85
1000.00
y
12/4/2007
1 :07 PM
Slip 10
Dates and Time
Posting Status
Description
31494 EXP
9/27/2007
WIP
Robson Forensic Costs
31892 EXP
9/28/2007
WIP
W.P. Kilareski, PC- Review and analysis of case
documents
32001 EXP
10/5/2007
WIP
Robson Forensic- Teleconference
Grand Total
Salzmann Hughes, P.C.
Slip Listing
Timekeeper
Activity
Client
PRB
Cost Advance
Dagan, Paul, P.
OHM
Cost Advance
Dagan, Paul, P.
OHM
Cost Advance
Dagan, Paul, P.
Billable
Unbillable
Total
Units
DNB Time
Variance
1
0.00
0.00
0.00
Rate
Rate Info
Bill Status
841.77
226.25
1398.30
Page
2
Slip Value
841 .77
226.25
1398.30
6176.85
0.00
6176.85
In Re: IAN PAUL DAGAN
ORPHANS' COURT DIVISION
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 21-07-0523
CERTIFICATE OF SERVICE OF ORDER
ORDER DATE: 1-2-07
JUDGE'S INITIALS: EEG
TIME STAMP DATE: 1-2-08
IN RE: ORDER
SERVICE TO:
JIM HUGHES
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
o USPS
DRRR
~ HAND DELIVERED
o OTHER_
o PETITIONER
o JUDGE
o CLERK OF ORPHANS COURT
MAILED: 1-2-08
SERVICE TO:
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
o USPS
DRRR
o HAND DELIVERED
o OTHER_
o PETITIONER
o JUDGE
o CLERK OF ORPHANS COURT
MAILED:
'J:h'cU-hrLt u cphMOV
Deputy
Clerk of Orphans' Court